OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

June 24, 1992

Mr. R.E. Blake
Sales Manager
Sonny Scaffolds, Inc.
319 Harlaw Drive
Mooresville,Indiana 46158

Dear Mr. Blake:

This is in response to your letter of April 21, in which you request clarification of the Occupational Safety and Health Administration (OSHA) regulations for scaffold casters. I apologize for the delay in responding to your inquiry.

You are correct that current OSHA standards at 29 CFR 1910.29(a)(4) require that "All scaffold casters shall be provided with a positive wheel and/or swivel lock to prevent movement". This is a general industry provision that has been identified by OSHA as being applicable to the construction industry, and the plain reading of the provision shows that caster brakes, which lock the wheel only, meet the requirement. This language was incorporated into the 1986 Notice of Proposed Rulemaking for scaffolds used in construction (51 FR 42680 at 42711).

In regard to OSHA's policy on the locking of casters and wheels, please be advised that 29 CFR [1926.452(w)(2)], in effect since 1971, states, in relevant part, that manually propelled mobile scaffold "in use by any persons shall rest upon a suitable footing and shall stand plumb. The casters or wheels shall be locked to prevent any movement".      (Correction 10/02/98) ["... casters and wheels shall be locked with positive wheel and/or wheel and swivel locks, or equivalent means, to prevent movement of the scaffold while the scaffold is used in a stationary manner."]

If you have any questions, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance (202) 523-8136.

Sincerely,

Patricia K. Clark, Director
Directorate of Compliance Programs